Uniloc USA, Inc. et al v. NATIONAL INSTRUMENTS CORP. et al

Filing 281

Agreed MOTION to Dismiss Defendants SafeNet, Inc., Aladdin Knowledge Systems, Inc., and Aladdin Knowledge Systems Ltd. by Uniloc Singapore Private Limited, Uniloc USA, Inc.. (Attachments: # 1 Text of Proposed Order)(Nelson, Edward)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
TYLER DIVISION

UNILOC USA, INC. and UNILOC
SINGAPORE PRIVATE LIMITED,
Civil No. 6:10-CV-472-LED
Plaintiffs,
v.
JURY DEMANDED
NATIONAL INSTRUMENTS CORP., et
al.,
Defendants.

AGREED MOTION TO DISMISS SAFENET, INC., ALADDIN KNOWLEDGE
SYSTEMS, INC., AND ALADDIN KNOWLEDGE SYSTEMS LTD.
NOW COME Plaintiffs Uniloc USA, Inc. and Uniloc Singapore Private Limited
(collectively, “Uniloc”), on the one hand, and Defendants SafeNet, Inc. (“SafeNet” ) and Aladdin
Knowledge Systems, Inc. and Aladdin Knowledge Systems Ltd. (together, “Aladdin”), on the
other hand, and respectfully move the Court to dismiss this cause of action between them, and in
support thereof would respectfully show the Court as follows:
All matters in controversy between and/or among Uniloc and SafeNet and Aladdin have
been settled and compromised, and these parties agree that each party shall bear its own costs,
expenses, and attorneys’ fees.
WHEREFORE, PREMISES CONSIDERED, these parties jointly pray that all claims by
Uniloc against SafeNet and Aladdin be dismissed with prejudice, and that all counterclaims by
SafeNet and Aladdin against Uniloc be dismissed with prejudice, with all attorneys’ fees and
costs of court to be borne by the party who incurred them.

DATE: October 21, 2011

Respectfully submitted,
/s/ Edward R. Nelson, III
Edward R. Nelson, III
Attorney-in-Charge
Texas State Bar No. 00797142
Barry J. Bumgardner
Texas State Bar No. 24041918
Steven W. Hartsell
Texas State Bar No. 24040199
S. Brannon Latimer
Texas State Bar No. 24060137
Jaime K. Olin
Texas State Bar No. 24070363
NELSON BUMGARDNER CASTO, P.C.
3131 West 7th Street, Suite 300
Fort Worth, Texas 76107
[phone]
[phone] (fax)
[e-mail]
[e-mail]
[e-mail]
T. John Ward, Jr.
Texas State Bar. No. 00794818
J. Wesley Hill
Texas State Bar. No. 24032294
WARD & SMITH LAW FIRM
111 West Tyler St.
Longview, Texas 75601
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
COUNSEL FOR PLAINTIFFS UNILOC USA,
INC. AND UNILOC SINGAPORE PRIVATE
LIMITED

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CERTIFICATE OF SERVICE
The undersigned certifies that on October 21, 2011, the foregoing document was filed
electronically in compliance with Local Rule CV-5(a). As such, this motion was served on all
counsel who have consented to electronic service. Local Rule CV-5(a)(3)(A).
/s/ Edward R. Nelson, III
Edward R. Nelson, III
NELSON BUMGARDNER CASTO, P.C.

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